CORAL RACING LIMITED APPLICATION FOR A PREMISES LICENCE GAMBLING ACT CROCKHAMWELL ROAD, WOODLEY, READING APPLICANTS BUNDLE OF DOCUMENTS

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1 CORAL RACING LIMITED APPLICATION FOR A PREMISES LICENCE GAMBLING ACT CROCKHAMWELL ROAD, WOODLEY, READING APPLICANTS BUNDLE OF DOCUMENTS Operational Information 1. GamCare Certificate 2. Proposed Layout 3. Photographs of similar Coral Shop 4. Photograph showing proximity of Coral Shop to Earley secondary school 5. SafeBet Alliance 6. Think 21 Policy 7. Think 21 test result 8. Self Exclusion Policy 9. Interaction Policy 10. Responsible Gambling Briefer 11. Coral Commitment to Social Responsibility 12. ABB Code for Responsible Gambling September SENET Announcement 14. Shop Signage Regulatory Information 15. Gambling Act 2005 s LCCP in respect of Betting Office Premises 17. Gambling Act 2005 (Mandatory and Default Conditions) (Engalnd and Wales) Regulations Wokingham Borough Council Gambling Act 2005 Policy

2 Awarded to Coral Racing Ltd This is to certify that following an inspection of a number of premises operated by the above company, GamCare is pleased to award certification for high standards of socially responsible practices Dirk Hansen Chief Executive, GamCare Valid until July 2016

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4 Recent example of a similar style Coral shop

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6 Coral 6 The Parade, Earley - This shop is adjacent to Maiden Erlegh School entrance J-1 j L IN It- ti Wei \ \ F - js _ - iv Ik 114. Coral School Entrance School outlined in red

7 NZ 73! i;. :hc" - --n, Coral Racing 6 the Parade Silverdale Road Earley. The Walking time to Maiden Erlegh School is 30 seconds Ka~ Entrance to Maiden Erlegh School, it is a college for year olds

8 Voluntary Code of Safety and Security National Standards for Bookmakers June 2014 Copyright 2014 by Association of British Bookmakers Limited. All rights reserved.

9 Table of Contents Acknowledgements... Foreword... Introduction... Definition: Work Related Violence... Understanding the Standards... Section A: National Standards- Violence in the Workplace... Section B: National Standards - Risk Assessment... Section C: National Standards Crime Prevention... Section D: National Standards Security and Safety measures... Section E: National Standards Training... Appendices Appendix1 Appendix 2 Appendix 3 Appendix 4 Appendix 5 Appendix 6 Appendix 7 Appendix 8 Violence in the Workplace ( ViW ) Example Policy for Smaller Bookmakers Health and Safety Risk Assessment Form Blank Health and Safety Risk Assessment Form Completed Example National Occupational Standards for Prevention of Work Related Violence ( WRV ) Model Data Collection List of Resources, References & Websites Example Incident Report Form Stakeholder Group Contact Details and Feedback

10 Purpose of This Document This document outlines agreed voluntary standards of workplace safety and security for the betting industry in England, Scotland and Wales with a view to reducing the risk of robbery and other forms of violence in the workplace. Please Note The Association of British Bookmakers ( ABB ) in offering this advice wishes to make it clear that: Operators are not exempted from their own statutory responsibilities: Legislation may change over time and the advice given is based on the information available at the time the guidance was produced. It is not necessarily comprehensive and is subject to revision on the light of further information: This advice is not intended to be a definitive guide to, nor substitute for, the relevant law. Independent legal advice should be sought where appropriate; and The purpose of this document is to provide advice to bookmakers and should not be used in anyway such as to impose legal responsibilities on bookmakers over and above their statutory responsibilities. Acknowledgements This document has been developed by the Association of British Bookmakers in conjunction with an external industry stakeholder group which includes representatives from: Metropolitan Police, Community Union, the Institute of Conflict Management and Crimestoppers. There is universal commitment on behalf of all the operators consulted to develop best practice as far as the safety and security of Licensed Betting Office ( LBO ) staff is concerned. Other Industries Whilst this document has been developed primarily for the bookmaking industry with a view to managing the risk of violence within LBOs, it may also be of interest to stakeholders in other industries.

11 Foreword ASSOCIATION OF CHIEF POLICE OFFICERS OF ENGLAND, WALES AND NORTHERN IRELAND Violent crime affects many high street operations, assaults and robbery cause great distress to staff and customers. These offences can result in devastating consequences including, in some cases, the business closing down. The Association of British Bookmakers and its members have worked tirelessly to identify an achievable, realistic and cost effective solution to reduce the offences against their members, staff and customers. In 2009, working closely with the police and other key agencies the industry identified a set of security policies and procedures, which bookmakers would be able to adopt, implement and most importantly, sustain. These standards were named The Safe Bet Alliance. The Safe Bet Alliance has proved to be not only an effective tool for reducing violent crime, but also a clear example of best practice for partnership working. The collaboration of police, bookmakers and other key stakeholders has led to an initiative that has stood the test of time. The Safe Bet Alliance has been in operation since 2009, in the first year, in London alone, there was a 46% reduction in robberies and a 55% detection rate. The decline in offences has continued, highlighting the sustainability of the initiative. In 2011 the Safe Bet Alliance won the prestigious Home Office Tilley award for Acquisitive Crime reduction. This award highlights the continued commitment of the ABB and its members to a safer betting environment. The standards have also assisted local licensing officers to identify consistent and relevant security measures for bookmakers. I commend the work of the ABB and those associated with the document and recommend it as essential reading for all bookmakers and licensing officers. Matt Jukes South Wales Police Assistant Chief Constable ACPO Commercial Robbery Area Lead

12 Introduction Having been operating on the high street and in town centres for over fifty years, betting shops now serve eight million customers a year, and employ over 40,000 people. Generally, betting shops offer customers and staff a safe and secure place to enjoy their leisure time or work. As with any other retail business, bookmakers can and do suffer from crime, including robberies and work-related violence The Safe Bet Alliance was formed in 2010 to tackle collectively these sorts of crimes both as an industry and with law enforcement and other partners, including the Metropolitan Police, Community Union (representing staff), Crimestoppers, local government and the Institute of Conflict Management. Since its formation, the Alliance has achieved some real successes the number of robberies for example fell in London by 60% in two years, and won the prestigious Home Office Tilley Award. The SBA has now, as you will have seen, also been endorsed by the Association of Chief Police Officers. Over recent months, the Safe Bet Alliance has been meeting to review our progress and see where we can build on success or improve in other areas. This updated document sets out the new guidelines, and which I believe will help the Safe Bet Alliance go from strength to strength. Sarah Simpson MBE Chair, Safe Bet Alliance Institute of Conflict Management

13 Definition: Work-Related Violence Work related violence is described by the Health and Safety Executive (HSE) as: Any incident in which a person is abused, threatened or assaulted in circumstances relating to their work. Examples of violence in the workplace are set out below: verbal abuse, in person, over the telephone or by ; unreasonable and/or offensive remarks or behaviour; written abuse; rude gestures; intimidation; harassment, including sexual and racial abuse; threatening behaviour e.g. squaring- up without physical contact; ganging up, bullying and intimidation; physical or sexual assault; spitting; malicious damage to the property of staff, customers or the business. The effects of violence in the workplace will vary from individual to individual, however all examples of violence should be treated seriously. Understanding the Standards All the voluntary standards contained in this document deal with measures aimed at reducing the risk of robbery and other forms of violence in the workplace. However the document is split into five Sections (A to E) for ease of use by operators. Section A sets out voluntary standards aimed at reducing violence in general. These standards recommended the adoption of operator-wide policies and procedures. Section B describes the five steps to reducing risk, explains the importance of the shop-specific risk assessment and offers guidance on carrying out the risk assessment. Section C states the key principles of crime prevention. Section D sets out the voluntary national standards that define specific security and safety measures designed primarily to reduce the risk of robbery, albeit with the additional benefit of helping to reduce the risk of other forms of violence. Operators are encouraged to apply appropriate security and safety measures for each shop based on the findings of a shop-specific risk assessment. Section E covers the voluntary national standards on training which are critical to the successful implementation of the standards.

14 Section A: National Standards - Violence in the Workplace 1 Policy Adoption 1.1 LBOs are generally safe places for staff and customers, but some LBO staff, like other staff in the retail sector, experience incidents of violence in the workplace. LBO operators will take all reasonable steps to prevent and respond to incidents of violence, up to and including reporting incidents to the police for possible prosecution. 1.2 The risk to staff from violence in the workplace needs to be included in the wider risk assessment process. Protecting the welfare of LBO staff going about their business is just as important as managing the risk of LBO robbery. 1.3 Many of the security measures put in place to protect against robbery also reduce the risk of physical injury to LBO staff. However those measures do not rule out the possibility of staff facing abuse or aggression which can have negative consequences both for the individual and for the business. 1.4 Facing assault, abuse or aggression or having to work in an intimidating environment is not part of the job and all reasonable measures should be taken to reduce the risks of these incidents. 2 Consequences of Violence in the Workplace 2.1 Work-related violence has serious consequences for employees, the businesses they work for and the wider community. 2.2 Consequences for employees Victims may suffer both physical injury and psychological harm including anxiety and stress. The cumulative effect of sustained verbal or physical abuse can wear someone down, both mentally and physically. Even if other members of staff seem to be coping, some individuals may experience feelings of isolation, fear, anxiety, suffering, humiliation, loss of confidence, reduced self-esteem and de-motivation Stress arising from violence in the workplace can damage physical health, social relationships and the way people function at work and at home. Stress can manifest itself in a range of symptoms including the following: i. physical signs like headaches, insomnia, indigestion, high blood pressure, alopecia, loss of appetite; ii. iii. iv. emotional factors such as irritability, lack of concentration, anxiety, loss of confidence, low morale; behaviour aspects such as poor work performance, accidents, poor relationships at home and work; abuse possibly leading to dependence on tobacco, drugs and alcohol; v. immediate, and often long-term disruption to interpersonal relationships; vi. if the situation persists, physical illness, psychological disorders. It is important to remember that these symptoms may have nothing to do with stress but they are often danger signs which should not be ignored. Stress may - if unrelieved ultimately contribute to other physical and psychological disorders including clinical depression. 2.3 Consequences for business For employers violence in the workplace can represent a real financial cost through: i. low staff morale contributing to high staff turnover. This in turn may affect a business profitability and even its viability;

15 ii. iii. low staff morale contributing to poor staff performance, reducing revenues and increasing costs; increased commercial insurance premiums; iv. sick pay for staff who are absent as a direct or indirect result of violence in the workplace; v. compensation claims, including not only the value of the claim itself and any legal fees but also the management time required to deal with it; vi. damage the company s image which may make recruitment more difficult and/or costly. 2.4 Consequences for the wider community The costs of dealing with the impact of violence in the workplace include: i. costs of health care and long-term rehabilitation for victims; ii. iii. costs of unemployment and retraining for victims who lose or leave their jobs; breakdown of trust in society.

16 3 Developing a Policy on Violence in the Workplace 3.1 All LBO operators are expected either to develop a separate policy on violence in the workplace issues or to incorporate the elements of such a policy into existing health and safety policies. This document provides references to source material that should help to enable all operators to develop their own policy on violence in the workplace. 3.2 A policy document should include the following: i. a definition of violence in the workplace; ii. a commitment to monitoring and reducing the number and severity of incidences of violence which emphasises how seriously this issue is taken by the organisation; iii. identification of who within the organisation is involved in the implementation of the policy, a description of their role and responsibilities as relevant to the policy, and noting any links that they may have with relevant third parties; iv. general advice on staff behaviour/ prevention advice; v. explanation of the risk assessment procedure; vi. vii. viii. ix. list of any agreed control measures that can be applied; summary of all training available; explanation of the reporting procedure and a copy of the relevant form; a summary description of the support available to victims. 3.3 Procedures should be reviewed annually or after a serious incident, whichever is the earlier. The policy should be discussed on a regular basis in staff forums. 3.4 Risk assessments should also consider the risk to ancillary staff on the premises (e.g. cleaners, maintenance staff) and visitors and the possible need to make special arrangements to manage any risk of violence towards them. 4 Training 4.1 As part of an employee s induction training, there should be awareness training regarding issues of violence in the workplace. After initial training, staff should: i. be aware of the issue of violence in the workplace; ii. understand any relevant policies and procedures issued by their employer in order to manage the risk of violence. 4.2 There should be both ongoing and refresher training that should allow staff to: i. know how to prevent and reduce violence in the workplace; ii. be able to deal appropriately with difficult, aggressive or violent customers.

17 4.3 The ABB has developed a basic training package on dealing with violence in the workplace. It is necessary for operators to carry out a training needs analysis and either to develop further in house training programmes or identify third party providers who can provide relevant training in conflict management. 4.4 It is reasonable that staff should receive training within their induction programme and on a continuing basis. See Section E. 5 Incident Reporting 5.1 Beyond meeting the business statutory responsibilities, there are a number of further advantages in encouraging comprehensive reporting of incidents. These include: i. it indicates to staff that the issue is taken seriously and that violence in the workplace is not regarded as part of the job ; ii. iii. it allows the business to monitor trends, to react to emerging findings and to inform the ongoing risk assessment process; it provides a platform for a cultural change if one is needed. 6 The Reporting Threshold 6.1 There is sometimes debate about when an incident should be reported. For example one person may find an incident disturbing or upsetting whereas another may not be affected. To ensure that incidents are readily reported, management should not impose their own threshold, but staff should be encouraged to report incidents which fall within the definition of violence in the workplace provided above. Even if others think the incident is low-level but that particular member of staff perceives it to be abuse or aggression then it should be reported. 7 A Clear and Effective Reporting Policy 7.1 LBO staff should clearly understand how to report incidents and to whom. The depth of the report and the response to it should be proportionate to the seriousness of the incident being reported. The reporting process should be standardised with a standard report form and a clear route for the report. It should be clear whose responsibility it is to review and investigate. Reported incidents should be categorised so that internal statistics can be readily maintained and trends monitored. 7.2 It is suggested that the incident report should contain the following information: i. form of assault (e.g. weapon, physical, biting, hitting); ii. form of abuse or threatening behaviour (e.g. swearing, sexual harassment, racial harassment, damage to the fabric of the building); iii. surrounding circumstances of the incident (identifying flash points, details of witnesses etc); iv. timing of the incident; v. outside agencies involved/medical attention needed; vi. area of incident (e.g. counter, gaming machines, customer area).

18 7.3 Staff should be confident that a reported incident will be properly considered and where necessary investigated. Feedback on the outcome of any investigation should be made to the person who made the report (even if only to explain why enquiries into an incident could not be progressed any further). Communication is fundamental to the process and is a key agent in cultural change. 7.4 In large organisations with central reporting processes, someone whom the member of staff involved recognises as being within their own immediate line management chain should be given responsibility for liaising with the person who made the report over the incident, including providing feedback and support. 8 Support for Victims 8.1 After an incident a member of staff (or group of staff) may require support. The nature of that support will be governed by the seriousness of the incident. The key points to remember are: i. victims of aggression will be affected in different ways and with differing levels of severity; ii. sensitive and appropriate support is needed to reduce the suffering of the victim; iii. there may be a requirement for further training. 8.2 In the case of more serious incidents, LBO staff should be fully aware of what to do in the immediate aftermath of that incident. This will include immediate medical and welfare support for the victim, having a clear communications strategy (notifying the police, operations room, security staff and relevant managers), preserving evidence at the premises and securing the premises. 8.3 Staff should be given an opportunity to talk openly about the incident, express their feelings and should receive constructive support. People are more likely to cope with an incident, be less afraid, and have increased job satisfaction and commitment, if they get positive support from colleagues and managers. But bear in mind that some people will not wish to talk about the incident, or may wish to do so at a later date. 8.4 Whilst the welfare of the victim is paramount, consideration should be given to the effect on other staff of any reported violence. This includes staff who may not have been involved in the incident or even present at the time that it occurred. 8.5 If it is available, staff could be offered confidential counselling services. These may be offered either in-house or from local professionals such as Victim Support or GP services. Managers should ensure that staff know that counselling is available and encouraged. Where in-house services are offered, employers should ensure staff are fully trained and competent. 8.6 Any time off which may be necessary for recovery should be granted, and sympathetic and supportive contact with victims maintained in accordance with the operator s HR policy. After the victim returns to work, managers will need to continue to lend support and monitor for ongoing effects of the incident. 9 External Agencies The LBO Manager should liaise with their local police Safer Neighbourhood Team on an ongoing basis. The Safer Neighbourhood Team may be contacted via the local police authority.

19 10 Conclusions 10.1 Following the advice in this document and meeting the relevant standards will not prevent all incidents happening, but it will reduce risk and enable LBO staff to deal more effectively with incidents Those responsible for developing and delivering policies and procedures in this area can find more information on the HSE website. This includes a toolkit at: An example policy that can be used by smaller LBO operators can be found as Appendix 1.

20 Section B: National Standards - Risk Assessment 1 The importance of risk assessment 1.1 The standards aimed at robbery reduction are LBO-specific and therefore underpinned by risk assessment. For operators with five or more staff, risk assessments must be in writing, but in any event operators must be able to demonstrate that they have carried out the process. It is a requirement of Regulation 3 of the Management of Health and Safety at Work Regulations 1999 for the significant findings of a risk assessment to be recorded in a retrievable format where the employer has five or more employees. The employee number relates to the entire business not just in one shop, so if the business has five shops all employing one person there is requirement to record the risk assessment findings. 1.2 A standardised process can be used to assess the risk of robbery The ABB believes that it is right to use a risk assessment methodology that will already be familiar to many LBO operators and their staff. The Health and Safety Executive s five steps to risk assessment reflects good risk assessment practice. Some operators already have a formalised approach to risk assessment. For example, they use between two (general or enhanced) and five categories of risk. 1.3 Participation in the Safe Bet Alliance does not necessarily entail redesigning existing formal process, but making sure that the operator takes a structured approach to risk assessment. 1.4 The key is following the five steps to risk assessment and determining what preventive or crime reduction measures are appropriate to manage the risks. For ease of reference the steps are: i. identifying the hazards; ii. deciding on who might be harmed and how; iii. evaluating the risks and deciding on precautions; iv. recording the findings and implementing them; and v. review.

21 1.5 Not all LBOs present the same risk. Some LBOs have never been robbed. An LBO may be located in an area where there is little or no business or street robbery. However, the process of carrying out risk assessments must be dynamic to meet emerging circumstances. All risks must be considered. 1.6 The appropriate starting point is proportionate and evidence based standards for all LBOs, with a menu of enhanced measures being used when risk assessment shows that a particular premises presents a greater risk. Where there is a higher level of risk then further measures need to be taken. 1.7 There are a range of professional and factual judgments to be applied when deciding what are the appropriate control measures to be applied in a particular LBO; for example, an analysis of trends and the strengths and weaknesses of particular crime prevention measures. This document assists with that analysis. 1.8 As part of the risk assessment process which should be premises specific, local management and LBO staff must be consulted. An assessment should take account of the age and experience of the staff working in the premises. Younger or less experienced staff may lack the interpersonal skills to effectively manage the risk of violence without the support of colleagues. 1.9 There are two distinct statutory schemes covering staff consultation on health and safety issues: one where unions are recognised by the employer and the other where they are not. As a minimum, it is important to make sure that consultation mechanisms are established which ensure that either all employees or elected representatives of employee safety are consulted. Further details can be found on the HSE website In coming to a view about the level of risk, the most simple and objective method for existing shops is to take into account the most relevant and current crime and other statistics and also consider the history of a particular premises in terms of the number and type of incidents to which it has been subjected. For example, if the statistics show that the risk of business robbery and other crime is low and there has been no history of robbery in that shop (say in the past two years) then that shop may be lower risk for robbery. For new shops one should consider the crime statistics and the experience of other similar shops in the immediate area Likewise the identification of a pattern of offences occurring in a particular area may require reevaluation of the risk in particular shops even if the particular shop in question has not been subject to a serious offence. The number of robberies in a particular area or region endures will be a determining factor when carrying out a risk assessment Following risk assessment, it will be necessary to justify the measures taken to reduce the risk of robbery. The key question is: Were the measures taken to reduce the identified risk reasonable and proportionate in the circumstances? 1.13 Whilst the large and medium sized operators have their own professional security staff, other sources of information are local police crime prevention and police Safer Neighbourhood Teams, local Environmental Health Officers and local business crime reduction partnerships. Some of the larger metropolitan forces publish their own business crime statistics at area level Carrying out the risk assessment and taking appropriate action is the responsibility of the operator. Where there are gaps in an operator s knowledge or expertise, then consultation with those external resources identified above is very much part of the process Nobody wants to see a rise in the level of robbery or other incidents in their area and betting operators should give every assistance to local crime prevention and investigating officers, particularly during a spate of local robberies when risk assessments may need to be revised to meet the changing circumstances. Whilst it is hoped that this will never be the case, this does not mean agreeing to requests for the implementation of disproportionate security measures across whole estates as a reaction to a spate of localised incidents A partnership approach should be adopted, but ultimately it is for the operator, having consulted where necessary with those responsible for health and safety compliance and the prevention and detection of crime,

22 to implement the appropriate measures to reduce risk. Adopting the standards set out below will assist operators to meet their legal obligations. The ABB can help independent members determine their current level of risk from LBO robbery and advise on the suggested measures set out in the tables below. The five steps involve identifying the risk (in this case the real risk of robbery and violence in the workplace), identifying what has been done already to reduce risk, establishing what else needs to be done, and finally who is responsible for delivering the agreed measures and reviewing the process A practical example of this approach in action can be seen on the HSE website Crime prevention techniques and methodology obviously come in to play here. Designing an LBO to reduce the risk of robbery (by limiting the opportunity or inclination of a potential offender to commit the crime) or implementing measures to deal with a particular situation and look at making individual betting premises a harder target for attack, is all part of the process However, many medium sized and small betting operators do not have the resources to employ specialist security staff (it is another function of management) nor do they have funds to pay for expensive reviews by security consultants. Therefore following an approach which is already in use by many operators to manage their health and safety risk and spreading simple and effective practice across the whole industry seems sensible. Experience has also shown that Crime Prevention, Licensing Authority and Environmental Health Officers also encourage this approach Whilst all reasonable measures should be taken to reduce robbery and other risks, it is also important to provide support for staff after an incident has occurred consistent with that contained in the Violence in the Workplace Policy.

23 Section C: National Standards Crime Prevention Whilst it is staff that should be encouraged to adopt the following principles, managers must implement and constantly reinforce them. 1 Crime prevention 1.1 Being vigilant - This means maintaining awareness of what is happening in the shop, identifying unusual occurrences or suspicious individuals and not being afraid to report suspicions to the police. 1.2 Giving good customer service - Great customer service reduces the risk of robbery. Building relationships with your existing customers, challenging strangers with a Can I help you? and running a clean and efficient shop discourages would be offenders. 1.3 Minimise cash - minimising the amount of cash that an offender can get their hands on is the single most important factor in reducing the incidence of robbery, preventing repeat robberies or stopping a spate of robberies by the same individual or group. This means making sure large amounts of cash are not available at the till and, where available, time delay safes or other dispersal alternatives are used. 1.4 Utilise existing security measures properly - This means following established security procedures, ensuring security equipment e.g. CCTV is working at all times and that security devices where fitted, such as Maglocks are working at all times 1.5 Avoid establishing a routine staff should avoid banking or emptying machines at the same time and establishing predictable patterns for would be offenders to observe. 1.6 Stay calm and remain passive, but in control whilst staff should do as the offender asks and never do anything to challenge the offender, there may be things that staff can do which help the situation. For example, breaking eye contact or appearing to comply with instructions while looking at opportunities to preserve evidence. Staff should do no more than they are asked to e.g. staff should not volunteer concealed cash or security processes. This could put colleagues in danger. 1.7 If robbed, the shop must be secured immediately after the incident - The shop is a crime scene where police may be able to recover forensic evidence, including DNA. Staff should preserve the scene by not touching or moving anything and prevent access by members of the public (although this does not mean ushering out those customers who were present during the incident). 1.8 All these principles should be underpinned by staff training. 2 The Ten Principles of Crime Prevention 2.1 Target hardening. 2.9 Rule setting Increase the chance of being caught. 2.2 Target removal. 2.3 Remove the means to commit crime. 2.4 Reduce the payoff. 2.5 Access control. 2.6 Visibility/surveillance. 2.7 Natural surveillance. 2.8 Environmental design.

24 Section D: National Standards Security & Safety Measures 1.0 The following voluntary security standards are based on surveys of premises that have been subject to robbery offences, the 10 principles of crime prevention (see Section C), and good practice that is currently adopted within the bookmaking industry. 1.1 An off the shelf accreditation scheme for robbery prevention may not necessarily be appropriate for a LBO. 1.2 In tandem with providing proper training (see Section D) sometimes it will be necessary to impose these working practices if it is felt that staff will be better protected by their use. 1.3 The following voluntary security standards are colour-coded as follows: GREEN represents a standard that UK bookmakers have agreed to work towards as a national voluntary standard BLUE represents a guide to best practice that it may be appropriate to implement depending on the findings of a shop-specific risk assessment.

25 LBO Shop Front Location Advice Standard Front door The front door is the first opportunity for controlling entry to the LBO premises. It is important that the door and the doorframe are of sound construction. All locking mechanisms should be regularly maintained and meet relevant BSI standards. staff should be traine The front door and surround must be of sound construction and locks should meet relevant BSI standards. Where the risk of repeat robbery offences is assessed as significant at the site, an electromagnetic lock maglock or an alternative entry control system should be installed, except in exceptional circumstances. Staff should be trained to ensure these measures work well. Corporate Signage It is important that customers and staff are aware of the security used on the premises. It is a legal requirement to clearly advertise the use of CCTV and the reasons for its use. All CCTV usage must comply with Home Office rules. LBOs must have a clear corporate security notice that details security measures, and includes contact details Where CCTV is operated, the signage must incorporate a CCTV notice, and be compliant with Data Protection Act and Home Office guidelines. Corporate signage and / or VDU screens should indicate to customers that operators may refer offences committed against staff to the police. Advertising / door/windows It is important that staff have an opportunity to identify potential risks before they enter the premises. It is also important that members of the public can see into the premises. Where reasonably practicable, advertising should be restricted to allow for clear viewing into and out of the premises. Lighting In some premises the structure and internal layout of the premises prevents clear viewing. In such cases alternative security measures e.g. external CCTV should be considered. External lighting is important to support external CCTV (where installed) and clear vision to aid the use of maglocks etc. Where possible external lighting also assists to identify potential risk during hours of darkness. Care must be taken to ensure that lighting does not create mirror effects thus reducing visibility for staff.

26 LBO Shop Floor Location Advice Standard Furniture Consideration needs to be given to the type of furniture used within the LBO. Dependent on the risk, furniture may need to be secured to the floor or of such construction that it cannot be used as a weapon or tool for causing damage. Appropriate furniture must be used in the LBO. Where there is an identified problem consideration should be given to securing furniture or removing portable items e.g. stools. Customer Desks and writing benches Desks and benches placed near windows and doors in some LBOs can become attractive to undesirable customers e.g. drug dealers. These people cause a number of problems: Scaring off regular customers, Causing local disorder problems. Fire exits Fire exits are another potential entry / escape route for offenders. In some cases fire exits cannot be seen from the cash office. The introduction of alarms on all fire exits will ensure that staff will be aware when fire doors are opened. CCTV will allow the capture of images of persons using the door. Fire doors must not be used as an alternative entrance / exit from the LBO unless it is an agreed exit. When particular problems have been identified consideration should be given to the removal of desks and writing benches from front window positions where the structure of the premises permits. Liaison with local police to discuss appropriate action. All fire doors must have signage that the doors are only to be used in an emergency only. All fire doors must be fitted with appropriate locking systems. Fire exits not accessible to the public or viewable from the counter must be fitted with an audible alarm. Toilets Gaming Machines In LBOs where toilets are available to members of the public, staff need to be aware of the potential misuse of the facilities. Robbers have been known to wait in toilets until premises are closed. Where misuse becomes an issue consideration should be given to controlling entry to the toilets or withdrawing the facility. Certain issues can be linked to the operation of Gaming machines: Stolen money being laundered, Underage persons using the machines and Strengthened fire doors should be fitted as part of all new builds and refits All toilets must be regularly checked by staff for evidence of misuse and for anyone loitering there at closing Where there is evidence of misuse the management should control access to the customer toilets. Consideration should be given to temporarily withdrawing facilities if the control systems prove inadequate and misuse is evident. This may involve seeking advice from local police. A procedure must be in place that ensures that gaming machines are only opened when staff are sure that it is safe to do so in

27 Criminal Damage to the machines and robbery when being emptied. compliance with company policy. Gaming machines will operate following the policies set out in the ABB Code. Remote control on/off switch for the machines should be in the Cash Office, allowing isolation of the machines. CCTV to cover gaming machine areas and capture images. Company policies must make clear that machines must not be opened if it is not safe to do so. Signage It is important that internal signage should reinforce the message of the corporate signage at the points of entry. Security messages must be prominently displayed in the cash office by means of corporate signage and / or VDUs. Internal CCTV CCTV must be in good working order and fit for purpose for which it was installed. CCTV is essential for post robbery investigations. For this reason it is vital that at least one camera is capable of obtaining a head and shoulders image of all persons leaving the premises. A minimum of a second camera is required to see what has happened in the store. All CCTV images to be recorded using frame rates appropriate to the operational requirements. CCTV must provide clear images of the counter, entrances and exits. The camera angle, where possible, should capture the general floor area (including gaming machines) Consideration should be given to installation of a covert camera to capture facial images. Processes must be in place to allow police access to images as soon as possible following an incident. Images must be retained for a minimum period of not less than 14 days. A regular maintenance plan for the CCTV system must be in place All CCTV must comply with the Data Protection Act and should take account of the Home Office / ACPO National CCTV Strategy gov.uk/cctv/index.htm Lighting Lighting plays an important part in creating an environment that feels safe and secure. Lighting is also essential for the capture of CCTV images. Internal and external lighting should support high quality CCTV images and recordings.

28 LBO Cash Office and Counter Location Advice Standard Counter The door to the cash office is in many cases the last barrier between the public area and the safe and tills. It is important that this door and the surround are of suitable construction to withstand an attack, and open outward. Where fitted, doors and door surround must be of sound construction and where possible open outwards. For existing premises where doors open inwards, bolts are acceptable. Security Screens Hold Up Alarms Where the door to the cash office is a fire door there may be restrictions on the type of door and security used. Security screens serve two main purposes: prevention of assault of staff and a barrier to stop access to the cash office. Where criminal incidents or risk assessments result in premises being assessed as higher risk, screens should be installed. It is important that the security screen is correctly fitted and of the appropriate type. Re- assessment of the screen situation should take place following a significant incident. A Hold-Up Alarm may be operated to summon urgent Police assistance when an assailant enters a previously defined area with the obvious intention of harming or threatening any person within that defined area. Source: (ACPO 2008) All cash office doors should be of suitable construction and be secure. Where staff cannot see the exterior a spy hole or clear glass panel must be in place in the cash office door. Shops graded as high risk should have a security screen. Security screens should be of an appropriate height and construction to prevent offenders climbing over the screen. The gap between the counter and the bottom of the screen should be sufficiently restricted to make access by customers difficult Where a premise is identified as high risk, consideration should be given to having a full screen. Staff must have access to a shop telephone capable of direct dialling 999. Following an attack the police should be contacted using 999. Alarms may be fixed position or discreet personal holdup alarms carried by staff. Where hold up alarms are installed or made available, staff must be trained and confident in the use and operation of the alarm. Alarms must be appropriately placed and regularly maintained. Fitted alarms must go to a central

29 Cash minimisation Safes and time delay Reducing the amount of reward available to offenders is a key crime reduction principle. A realistic maximum limit for cash in tills must be identified for each store. All cash in excess of this limit must be placed in the safe, not hidden in the shop! It may be advisable in certain shops with a high cash turnover to fit a second hidden safe (floor) or a time delay mechanism or insert. Introducing a time delay mechanism or hidden safe reduces the chance of offenders obtaining large quantities of cash from the main safe. A maximum till limit must be identified for each LBO. The maximum limit must be enforced. It is unlikely that the maximum till limit will need to exceed 300 per till. It is highly recommended that all betting offices be fitted with a safe in an appropriate location. Where safes are used they must be closed and locked at all times when not in use. If fitted, inserts must remain locked unless in use. Banking Procedures Banking should take place as and when required. The following points should be noted. No fixed day or time should be arranged for banking. Staff uniform including badges must not be visible when banking. Excess cash should be placed in the safe. Banking must be a random activity not restricted to certain days or times. Staff and management must be trained in relation to banking procedures. Opening and Closing Opening Staff should remain vigilant when unlocking the premises, looking for anyone waiting in the vicinity of the premises. If the member of staff is suspicious of any person they should not unlock the shop but move to a place of safety where they can call police. Staff engaged to open premises should be fully trained and briefed and be given the confidence to delay or cancel opening if they are at all suspicious. Opening and closing procedures must be introduced and complied with. If it is safe to do so once the door is opened staff should enter quickly locking the door behind them until they are ready to open the premises to the public. Closing Time Good preparation and teamwork is key. A check must be made of all

30 areas, toilets etc to ensure that no one is concealed within the building. Lock the door with the key don t rely solely on the maglock (where fitted). Now is the only time that the shop s total cash should be fully checked and counted. Lock all cash away in the safe equipment provided. It is advisable that if there are 2 staff members they leave together and maintain vigilance. If staff are suspicious of any person they should not leave the building, but wait until the person leaves or call police. Do not leave via back doors onto unlit areas and car parks etc.

31 LBO Procedures Location Advice Standard CCTV CCTV is essential for the identification and conviction of offenders. Consideration should be given by all operators to installing CCTV when new premises are opened or refitting is undertaken. A rolling programme of increasing CCTV coverage is desirable. Training Training is an essential element for security. Staff need to know what to do before, during and after a robbery. All staff from cleaners to managers and contractors play an essential role in reducing robbery. Appropriate training reduces the risk of injury, reduces the financial loss and improves the possibility of identifying and convicting offenders. All London betting offices should be fitted with internal CCTV (see above) All staff and operational managers and others should receive comprehensive security training to ensure that they are aware of their duties and responsibilities. Training for all staff must be provided in relation to robbery awareness. Refresher training needs to be undertaken at regular intervals Police Liaison Sharing information Recruitment and retention Liaison with local police officers is always advisable, irrespective of where you trade from and the associated risks. The method of policing has recently changed. With the introduction of Safer Neighbourhood Teams SNTs (and their local equivalents in Scotland who can be contacted via the local police station) there is a need for businesses to engage with the police at this local level. The SNT is a valuable resource for addressing local disorder problems, passing information and reassurance of staff and should be encouraged to visit the premises on a regular basis Local Business Watch type schemes do have advantages in reducing crime. The timely sharing of information, the ability to identify local issues before they become problems and the opportunity to communicate with police, local authority and other organisations make the time invested a worthwhile expenditure. It is essential staff are trustworthy and comply with security Establish who is the local Neighbourhood Police Team or equivalent and develop that relationship for advice, visits and support and know the contact number for local police team. Operators (especially those without dedicated security departments) should share information locally and consider affiliation to their local Business Crime Reduction Partnerships or similar initiatives like Crimestoppers, Betwatch or Facewatch. A robust recruitment and reference checking process should be in place

32 of staff Management of Staff Property Management procedures. Staff have access to cash on site and to security procedures and operations. All staff need to be vetted to the appropriate level. It is important to adopt a pro-active management style that has a positive impact on staff ensuring that they follow procedures at all times. Managers who fail to ensure that security policies are complied with are failing to manage. Disciplinary action should be considered for any breaches of procedure by managers or staff, taking into account all mitigating factors. Investment in security equipment can be compromised if it is not correctly installed and maintained. Unfortunately many investigations are frustrated because faulty CCTV has not been reported or remedied and robberies have occurred because of faulty installations e.g. incorrectly fitting maglocks. The shop manager, where possible, should ensure that all security equipment is working correctly and maintained to acceptable standards. Daily and periodic checks should be completed. for all potential employees. Managers must ensure that all staff have access to policies and procedures at all times and that they understand and follow those procedures. Where it is evident that security procedures have not been followed it is advisable that staff involved receive appropriate action in line with company policy. Security equipment must be correctly installed and maintained. A scheduled check of security equipment must be undertaken and a maintenance log maintained. Internal or external service level agreements should be in place with engineers. Incident Report Log A detailed log of all work required, date of reporting and date of rectification needs to be maintained by the manager. This log should include, where appropriate, to whom the matter was reported, date and time and outcome of the reported incident. Many offenders reconnoitre the premises prior to a robbery to identify what security is in place and how staff are likely to react. It is vital that details of suspicious persons and vehicles are recorded, as these events may be key to any investigation. Where schemes are in place it is important that relevant information is passed to the interested parties. All LBOs should record suspicious incidents in the shops incident log. Each entry must record the date, time and location of the suspicious activity. Details of suspicious persons must include a description including: gender age